SOUTH COAST AIR QUALITY MA AGEME T DISTRICT ENGINEERING & COMPLIANCE APPLICATION PROCESSING AND CALCULATIONS

PAGES 7 APPL. NO. 477953 PROCESSED By Thomas Johnny Lee Pan

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PERMIT TO OPERATE

COMPA Y AME A D ADDRESS Edgington Oil Company 2400 E. Artesia Blvd. Long Beach, 90805 Contact : Kathryn Gleeson Telephone: (562) 748-4613 Email : kgleeson@ppcla.com

EQUIPME T LOCATIO Edgington Oil Company 2400 E. Artesia Blvd. Long Beach, 90805 Facility ID: 800264

EQUIPME T DESCRIPTIO Additions are noted in underlines. Deletions are noted in strikeouts. Section D of Facility Permit, ID# 800264 (The following changes have been made in P3/S1, Sec. D of the Facility Title V permit).
Description ID o. Connected To RECLAIM Source Type/Monitoring Unit Emissions And Requirements Conditions

Process 3: TREATI G/STRIPPI G System 1: FUEL OIL CLAY TREATI G

SCRUBBER, PACKED BED, D310, CAUSTIC, HEIGHT: 35 FT; DIAMETER: 7 FT A/N: 387882 477953 TA K, SETTLER, D-1200, CAUSTIC, LE GTH: 31 FT; DIAMETER : 8 FT A/N: 477953 TANK, SETTLER, D-1201, CAUSTIC, LENGTH: 31 FT; DIAMETER : 8 FT A/N: 387882 477953 D283

Dxxx

D367

SOUTH COAST AIR QUALITY MA AGEME T DISTRICT ENGINEERING & COMPLIANCE APPLICATION PROCESSING AND CALCULATIONS
FILTER, SAND, D-1202, LENGTH: 10 FT 9 IN; DIAMETER: 6 FT A/N: 387882 477953 DRYER, SALT, D-1203, DIA.: 72 FT; LENGTH: 15 FT A/N: 387882 477953 DRYER, SALT, D-1206, DIA.: 6 FT; LENGTH: 16 FT A/N: 387882 477953 VESSEL, CLAY, D-1204 & D1205, 2 TOTAL, HEIGHT: 16 FT; DIAMETER: 6 FT A/N: 387882 477953 VESSEL, CLAY, D-1207, HEIGHT: 20 FT; DIAMETER: 7 FT A/N: 387882 477953 FILTER, F-1201 A/N: 387882 477953 FILTER, F-1202 A/ : 477953 FUGITIVE EMISSIONS, MISCELLANEOUS A/N: 387882 477953 D368

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D369

D370

D371

D372

D284

Dxxx

D332

H13.13

CO DITIO S

SOUTH COAST AIR QUALITY MA AGEME T DISTRICT ENGINEERING & COMPLIANCE APPLICATION PROCESSING AND CALCULATIONS

PAGES 7 APPL. NO. 477953 PROCESSED By Thomas Lee

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BACKGROU D Edgington submitted A/N 477953 on February 7, 2008 for the following changes in the Fuel Oil Clay Treating (FOCT) permit to more accurately portray the current state of the equipment in Process 3, System 1: Equipment ID(s) D-1200 D-1201 D-1202 F-1202 Requested Changes Add caustic settling tank D-1200 (identical to D-1201) to the permit. Correct equipment description typographical error from SETLER to read SETTLER. Correct equipment description typographical error from SAN to read SAND. Add filter, F-1202 (identical to F-1201), to the permit.

APPLICATIO SUMMARY The following table lists the application and fee submitted by EOC:
A/N 477953
1

Equipment All in P3/S1

BCAT1 300950

Status2 20

Type 50

Fee Schedule D

Fee Required $4,071.37

Fee Paid $4,680.85

Amt Due ($609.48)

Previous A/N 387882

This application was accepted with a wrong BCAT (333950), which resulted in an overpayment of permit processing fee. A refund of $609.48 will be made to EOC. The correct BCAT is 300950.
2

As a status 20 application, a decision was made to process it as a PC/PO and issue the permit in Section D. The addition of D-1200 should be an administrative change since previous C&C permits identified a second identical caustic settling tank to D-1201. The addition of F-1202 is a modification of the permit unit but the emissions impact from this change, which has already been made, is negligible and requires no post-modification source test.

EVALUATIO Equipment ID(s) Conclusion and Recommended Action Earlier C&C permits PO P68436 and PC C39747 (see Attachment 1) for this permit unit shows two identical caustic settling tanks with dimensions: 31L x 6D. It is recommended that this second unit be added back to the fuel oil clay treating (P3/S1) permit as D-1200 per EOCs request. It appears the second unit was inadvertently left off the permit when PC C39747 was converted to PO M28001. The typographical error for Settler was corrected during initial TV permit issuance in 2009 and is reflected in the most recent revision

D-1200

D-1201

SOUTH COAST AIR QUALITY MA AGEME T DISTRICT ENGINEERING & COMPLIANCE APPLICATION PROCESSING AND CALCULATIONS

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Equipment ID(s)

D-1202

F-1202

Conclusion and Recommended Action (#19) of Section D on 12-20-12. No action needed. The typographical error for Sand was corrected during initial TV permit issuance in 2009 and is reflected in the most recent revision (#19) of Section D on 12-20-12. No action needed. The addition of F-1202, which is identical to F-1201, should have negligible impact on emissions. It is recommended that filter F-1202 be added to this permit unit per EOCs request. Please see Emissions section for details. This is based on the following:

EMISSIO S The Fuel Oil Clay Treating unit (P3/S1) operates as a closed system during normal operating conditions. The only emissions associated with this permit unit are from fugitive components. Of the 19 lbs/day (AV30) of ROG emissions established in NSR for this permit unit, almost 90% (17 lbs/day) of it is attributed to the 7 PRVs installed on the scrubber, settling tanks, sand filter, salt dryers and clay pots. The remaining 2 lb/day is attributed to the 50 valves and 2 pumps within the entire permit unit. Please see engineering evaluation under A/N C-39747 for details. Just like filter F-1201, F-1202 is also not equipped with a PRV. Assuming, conservatively, that 6 additional valves were added to accommodate F-1202, the fugitive emissions increase can be expected to be ~0.23 lb/day (0.08 lb/hr 50 valves x 6 valves x 24 hr/day) using emissions factors from A/N C-39747. This is below the 0.42 lb/day threshold for any NSR implications. Such negligible increase is also not expected to have any impact on cancer risk (MICR), acute (HIA) and chronic (HIC) health indices at any receptor location. Hence, the overall emissions impact from the addition of F-1202 to this permit unit is negligible. The District refinery permitting unit has adopted the Correlation Equation Method for calculating fugitive emissions pursuant to AQMDs Guideline for Fugitive Emissions Calculations (June 2003, Method 2). The emission factors derived from this method is believed to be more accurate than the emissions factors used in A/N C-39747. Therefore, fugitive emissions for this permit unit were recalculated using this method for NSR update (see table below).

SOUTH COAST AIR QUALITY MA AGEME T DISTRICT ENGINEERING & COMPLIANCE APPLICATION PROCESSING AND CALCULATIONS

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Edgington Fuel Oil Clay Treating Unit (A/ 477953) Fugitive Emissions Using Correlation Equation Method (AQMDs Guidelines for Fugitive Emissions Calculations, June 2003, Method 2)
Fugitive Component Service No. of components, A/N C39747 No. of components, A/N 477953 A/N C39747 Emissions Factors, lb/yr Correlation Equation Factor, 500 ppm Screening Value, lb/yr 4.55 0 46.83 A/N C39747 Emissions, lb/yr A/N 477953 Emissions, lb/yr

Valve PRV Pumps Total Emissions, lbs/yr Emissions Decrease, lbs/day

Heavy Liquid Heavy Liquid

50 7 2

56 7 2

13.9 876 84

695 6,132 168

255 0 94

6,995

349

18

RULE REVIEW Rule 212 Standards for Approving Permits ovember 14, 1997 The subject loading racks meet all criteria in Rule 212 for PO issuance and are expected to operate without emitting air contaminants in violation of Division 26 of the State H&SC or in violation of AQMD rules and regulations. Public notice is not required because: R212(c)(1) The subject permit unit is well beyond 1000 feet from the outer boundary of a school. R212(c)(2) There is no emissions increase from the permit unit. Therefore, no increase in emissions greater than the daily maximum thresholds is expected. Rule 212(c)(3) Without any emissions increase, there is no increase in MICR or acute/chronic hazard indices.

Rule 401

Compliance is expected. Visible Emissions ovember 9, 2001 Visible emissions are not expected under normal operating conditions. Compliance is expected.

SOUTH COAST AIR QUALITY MA AGEME T DISTRICT ENGINEERING & COMPLIANCE APPLICATION PROCESSING AND CALCULATIONS

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REG X
40CFR 63, Subpart CC

ESHAP
ational Emission Standards for Hazardous Air Pollutants from Petroleum Refineries

EOC has provided data to the District to show that the Long Beach facility is not a major HAP source, which is defined as a source emitting 10 tons per year of any single HAP or 25 tons per year of all HAPs combined. As an area HAP source emitting less than these thresholds, the facility is not subject to any major source Maximum Achievable Control Technology (MACT) Standards, including 40CFR 63, Subpart CC, except for the reporting and recordkeeping requirements of 40CFR 61, Subpart FF National Emission Standard for Benzene Waste Operation. The Subpart FF requirements have been incorporated into the Title V permit as facility condition F16.1. Compliance is expected.
40CFR 63, Subpart A7

ational Emission Standards for Hazardous Air Pollutants for Area Sources: Asphalt Processing and Asphalt Roofing Manufacturing This rule limits PAH emissions to 0.003 lb/ton or PM emissions to 1.2 lb/ton of asphalt charged to the blowing stills at EOC. Pursuant to Table 4 of this subpart, ECO is utilizing its incinerator, B-501, to comply with this requirement and has indicated source test will be performed to demonstrate compliance as soon as asphalt blowing operations are resumed. According to an email from EOC dated 10/19/12 (contained in application folder 383221), the facility has not blown asphalt since the compliance date of 12/2/10. The upcoming source test (after asphalt blowing operation is resumed) will verify whether the current combustion zone temperature requirement of 1400F set forth in condition C8.1 is sufficient to satisfy the monitoring requirement of 63.11563. Compliance is expected. Note that although Subpart A7 is applicable to the facility, the applicable requirements of this subpart do not apply to the Fuel Oil Clay Treating unit.

Reg XIII
Rule 1303

SR
December 7, 1995 Requirements This rule specifies that the Executive Officer or designee shall deny the Permit to Construct for any new or modified source which results in a net emission increase of any nonattainment air contaminant, any ozone depleting compound, or ammonia, unless BACT is employed, Modeling is used to demonstrate no significant change (increase) in quality concentration and Offsets are provided. Since the permit action under this evaluation will not result in any emissions increase, the requirements of this rule do not apply.

Note that the PRV emissions (17 lbs/day) under A/N C-39747 discussed in the

SOUTH COAST AIR QUALITY MA AGEME T DISTRICT ENGINEERING & COMPLIANCE APPLICATION PROCESSING AND CALCULATIONS

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Emissions section should not have been included since they are emergency devices. The NSR emission has been recalculated, using the Correlation Equation Method, without the PRVs as shown in the Emissions section and the annual emissions of 349 lbs/yr will be entered in NSR. Reg XX Rule 2005 RECLAIM SR for RECLAIM June 3, 2011 EOC is designated as a NOx and SOx RECLAIM facility. However, the Fuel Oil Clay Treating unit is neither a NOx nor a SOx emissions source. As such, this regulation does not apply.
TITLE V PERMITS Requirements ovember 14, 1997

REG XXX Rule 3002

EOC is designated as a Title V facility. The initial Title V permit was issued on October 1, 2009. The permit action for D-1200 can technically be considered an Administrative revision of the TV permit because it is for incorporating equipment that was inadvertently left off the permit. However, the permit action to incorporate filter, F-1202 is considered a Minor TV permit revision because it does not meet the requirements for an Administrative, De Minimus or Significant revision pursuant to Rule 3000. As a Minor revision, the proposed permit and a copy of the evaluation will be submitted to the EPA for review. Compliance is expected. COMPLIA CE RECORD REVIEW A review of the Districts CLASS data base shows there are no pending compliance issues at EOC currently. CO CLUSIO Issue Permit to Operate (PO) for P3/S1 with the recommended permit actions in the Evaluation section above.